RD 373 - ETNO Response to the Draft BEREC High Level Principles on Issues of Non-Discrimination

ETNO welcomes the consultation launched by BEREC on the high level principles associated with non-discrimination. This is a matter of great impact and importance to ETNO members and ETNO hereby submits answers to the questions that are of concern to the association.

ETNO welcomes the consultation launched by BEREC on the high level principles associated with non-discrimination. This is a matter of great impact and importance to ETNO members and ETNO hereby submits answers to the questions that are of concern to the association.



ETNO welcomes the consultation launched by BEREC on the high level principles associated with non-discrimination.  This is a matter of great impact and importance to ETNO members and ETNO hereby submits answers to the questions that are of concern to the association.

ETNO considers that a well-functioning, non-discrimination obligation is an important remedy for bottleneck services in a relevant wholesale access market. It guarantees the equivalence of output, meaning that the access provider’s wholesale offers enable access seekers to provide the retail market with offers similar to those of the access provider.

ETNO supports BEREC’s overall approach to identifying high-level principles for the implementation of non-discrimination. The guidance in BEREC’s revised common positions on markets 4 and 5 should provide for consistent principles but should allow for sufficient flexibility for NRAs to enforce them in a meaningful, effective and proportionate manner, taking into account the specific market circumstances and the level of competition in each national market.